Finding 25516 (2022-002)

- Repeat Finding
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2022-11-09
Audit: 25905
Organization: Millikin University (IL)
Auditor: Sikich LLP

AI Summary

  • Core Issue: The University failed to return loan funds correctly for one out of twelve students who withdrew without passing grades, leading to noncompliance with federal regulations.
  • Impacted Requirements: The failure relates to 34 CFR 668.22, which mandates accurate calculations and timely returns of Title IV funds upon student withdrawal.
  • Recommended Follow-Up: Implement controls to ensure all disbursed awards are tracked accurately and maintain proper documentation for refunds to prevent future errors.

Finding Text

2022-002 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Criteria: 34 CFR 668.22 (a)(1) states ?When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.? 34 CFR 668.22 (e)(2) states, ?The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or?? 34 CFR 668.22(j) notes, ?(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in ? 668.173(b).? Condition: The University did not properly return loan funds subsequent to the R2T4 calculation for no passing grades withdrawal students for 1 out of the 12 students tested (8.3%) due to failing to return the required PLUS loans based on the calculation. Further, the amount of direct student loan funds returned was later disbursed to the student again due to lack of documentation in the University?s system of the unofficial withdrawal. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions and a repeat of prior year finding 2021-001. Statistical sampling was not used. Questioned Costs: $5,151 Cause and Effect: Without proper review of refund amounts returned, withdrawal students may return the incorrect amount of Title IV aid. Students should return the same amount as their Return of Title IV calculation. Recommendation: We recommend the University implement controls to help accurately track that Return of Title IV withdrawal calculations contain all awards disbursed and to be disbursed and that proper documentation is in the file when refunds are made. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan. See chart/table in report

Corrective Action Plan

2022-002 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Condition: The University did not properly return loan funds subsequent to the R2T4 calculation for no passing grades withdrawal students for 1 out of the 12 students tested (8.3%) due to failing to return the required PLUS loans based on the calculation. Further, the amount of direct student loan funds returned was later disbursed to the student again due to lack of documentation in the University?s system of the unofficial withdrawal. We consider this to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used. Management Response: The error identified above was made on a student?s record who did not officially withdraw from the University. As required by federal regulation, an ?all F?s? report is pulled at the end of each term and a determination is made for all students included on the report whether or not they attended classes until the end of the term. The student identified by the auditors was determined to have not attended the full Fall term. A return of title IV calculation was promptly processed by the Associate Director on the Department of Education?s website. The R2T4 calculation could not be processed via the SIS since the student did not have an official withdrawal date entered. The student loans were returned timely, however, the parent PLUS loan was missed in returning the funds. Subsequently the student contacted our office to challenge the withdrawal date and claimed he had attended classes all term and earned all of the loan funds that were disbursed for the term. There was no documentation in our SIS so the loans were reinstated in error. Corrective Action Plan: R2T4 procedures were updated to include a secondary confirmation of the return of loan funds according to the calculation. This secondary review will be scheduled at the time the R2T4 calculation is processed. Further, the procedure was updated to include entry of notes on the student?s electronic record to avoid reversal if challenged by the student. Responsible Person: Chilwana Thompson, Associate Director Implementation Date: August 1, 2022

Categories

Questioned Costs Student Financial Aid Special Tests & Provisions Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $13.72M
84.425 Education Stabilization Fund $3.10M
84.063 Federal Pell Grant Program $3.10M
84.038 Federal Perkins Loan Program $1.97M
84.033 Federal Work-Study Program $286,373
84.007 Federal Supplemental Educational Opportunity Grants $206,342
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $19,945
45.025 Promotion of the Arts_partnership Agreements $5,500